This bill amends the Internal Revenue Code to set forth rules governing corporate inversions (i.e., the practice of relocating a domestic corporation's legal domicile to a lower-tax nation while retaining its business activities in the higher-tax country of origin) and corporate expatriations. Specifically, the bill requires payment of tax on the deferred overseas profits of U.S. multinational corporations or partnerships before they reincorporate or organize in a foreign country. Additionally, any stock of a controlled foreign corporation in connection with a corporate expatriation would be treated as sold for its fair market value as of the date of expatriation and be subject to U.S. taxation.

The bill expands the definitions of "corporate inversion" and "corporate expatriation" and revises rules relating to the taxation of inverted corporations. A foreign corporation that acquires the assets of a U.S. corporation or partnership after January 4, 2017, shall be treated as an inverted corporation and thus subject to U.S. taxation if, after such acquisition: (1) the expanded affiliated group which includes the foreign corporation does not have substantial business activities in the foreign country in which the corporation is created or organized, when compared to the total business activities of such expanded affiliated group; and (2) more than 50% of the foreign corporation is held by former shareholders or partners of the domestic corporation or partnership, or the management or control of the expanded affiliated group occurs primarily within the United States, and such expanded affiliated group has significant domestic business activities.

]]>2017-04-05T04:00:00Z2017-04-05Introduced in HouseIntroduced in House2017-06-21T15:46:21Z00TaxationAdministrative law and regulatory proceduresCorporate finance and managementDepartment of the TreasuryForeign and international corporationsIncome tax ratesSecuritiesTaxation of foreign incomeShort Titles as IntroducedCorporate EXIT Fairness ActShort Titles as IntroducedCorporate EXpatriates and Inverters Tax Fairness ActOfficial Title as IntroducedTo amend the Internal Revenue Code of 1986 to discourage corporate inversions and to impose tax on unrepatriated earnings and unrecognized gains in connection with corporate expatriations.Display TitleCorporate EXIT Fairness Act(Extracted from GPO) Short Titles as IntroducedCorporate EXpatriates and Inverters Tax Fairness ActRep. Doggett, Lloyd [D-TX-35]D000399LLOYDTX35DOGGETT8181303D000399DTaxation3House floor actions2hswm00Ways and Means CommitteeIntroReferralReferred to the House Committee on Ways and Means.2017-04-05H11100Library of Congress9IntroReferralIntroduced in House2017-04-05Intro-HLibrary of Congress9IntroReferralIntroduced in House2017-04-051000111text/xmlENPursuant to Title 17 Section 105 of the United States Code, this file is not subject to copyright protection and is in the public domain.Congressional Research Service, Library of CongressThis file contains bill summaries and statuses for federal legislation. A bill summary describes the most significant provisions of a piece of legislation and details the effects the legislative text may have on current law and federal programs. Bill summaries are authored by the Congressional Research Service (CRS) of the Library of Congress. As stated in Public Law 91-510 (2 USC 166 (d)(6)), one of the duties of CRS is "to prepare summaries and digests of bills and resolutions of a public general nature introduced in the Senate or House of Representatives". For more information, refer to the User Guide that accompanies this file.